April 10, 2023

NSF's new Proposal and Award Policies and Procedures Guide (PAPPG, NSF 23-1) contains an update to the agency's policy on dual use research of concern (DURC) (i.e., research that uses one of 15 select agents, produces one of 7 effects, and has the potential to be misused).

NSF still prohibits funding DURC or gain of function research, but allows for research that could create enhanced potential pandemic pathogens (enhanced PPPs) if the benefits of the research far outweigh the risks. Proposing organization are now required to identify submissions proposing any DURC or work with enhanced PPPs by checking a box on the proposal cover pages labeled “Potential Life Sciences Dual Research of Concern.”

If a decision is made to fund the proposal, and use of a select agent (but not an enhanced PPP) as identified by the Policy is proposed, the proposer must submit evidence of registration of the select agent with the CDC or USDA as required by the Select Agent Regulations and the proposer must submit a justification from the Institutional Review Entity (IRE) demonstrating how the potential benefits of the research using the select agent far outweigh the risks. If a decision is made to fund a proposal using or potentially resulting in enhanced PPP, the proposer must submit a justification from the IRE demonstrating benefits outweigh the risks, but registration with CDC or USDA is not required.

More information can be found in Chapter II.E.6 and Chapter XI.B.5 of the new PAPPG.

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